St. Tammany Parish Hosp. v. Burris,
No. 2000 CA 2639 (La. Ct. App. Dec. 28, 2001)

A hospital sued the father of a minor patient for payment for services rendered to the child. The father argued that he was disabled and unable to pay the bill. He also argued that the hospital did not provide sufficient evidence that he was responsible for the bill. The hospital provided an affidavit that the debt was accurate and the trial court granted the hospital summary judgment. The father appealed. The Louisiana Court of Appeals reversed and remanded the case for further proceedings. The court found that the affidavit filed by the hospital was deficient in that it did not specifically identify the patient who received services. Nor was there sufficient evidence that the plaintiff was responsible for the debt. The court ruled that these deficiencies in the hospital's evidence raised issues of material fact that made summary judgment inappropriate.